Any Development, Any Place, Any Time – Where Next for the NSS?

After four years of little tangible progress in respect of planning policy agendas, the government recently published a new Planning Policy Statement (PPS)“to reaffirm its strong belief in the value of a forward-looking, visionary and dynamic planning process” together with the heads of two new planning bills. The first introduces a new vacant site levy and revised provisions in relation to social and affordable housing. The second presents proposals for the long-awaited planning regulator, following the recommendations of the Mahon Tribunal. It also sets out the legislative context for the successor to the National Spatial Strategy (NSS) – the National Planning Framework (NPF).

Both bills have also not been without their criticisms from, for example, the Irish Planning Institute and An Taisce. The proposed vacant sites levy mechanism appears so cumbersome so as to be unworkable in practice and exposes the strategic error in opting for a property tax over a more progressive Site Value Tax. I have previously blogged on the criticisms surrounding the independence of the planning regulator. Regulating planning is not like regulating the taxi industry. Planning is spatial politics – making choices on the use of land which are irreversible and will have profound intergenerational impacts. While I acknowledge that the track record of most former ministers inspires little confidence, the idea of handing such power over to a technocratic regulator outside of democratic oversight would be fraught with danger. It cannot be simply assumed that the regulator would be a benign or progressive force.

The high-level political commitment in the PPS is, of course, welcome – basic ‘Planning 101’ type stuff. The new mantra for the planning system is to ensure that “the right development takes place in the right locations and at the right time”. However, what is actually happening in the micro-politics of everyday practice, and which will no doubt continue, is more like ‘any development, in any location and at any time’. For example, in the majority of local authorities, ad hoc ‘one-off’ housing currently accounts for well over 70% of all new residential units granted planning permission and in many cases it is over 90% i.e. diametrically contrary to the lofty principles of the PPS.

The broader point here, and relevant to the preparation of the new NPF, is Niklas Luhmann’s famous assertion that planning is possible if people are used to being planned. Irish people clearly are not. The political class is equally apathetic, even ideologically hostile, to long-term policy planning. The reason the NSS failed was due to thousands of individual acts of resistance – death by a thousand cuts – which cumulatively undermined the whole foundations of the strategy. This was aided and abetted by the vague nature of NSS policies and objectives which simultaneously offered something to everyone and nobody at the same time. Text could always be pulled out of the NSS to justify almost any manner of development proposal regardless of location, the upshot being a complete loss of steering capacity.

While there will always be broad acceptance of notional long-term planning strategies and feel-good intentions as advocated by the PPS, short-term considerations will always win out in concrete practice. Such outcomes are often tied to emotional pleadings around children of landowners and the promise of local jobs which are impossible to resist. We are already seeing a return of the ‘development-at-all-costs’ culture which gripped the Celtic Tiger, where those questioning development proposals on the grounds of national policy are being pilloried by national and local politicians. Surely, it must be a concern that in almost 50% of planning cases where a decision of a planning authority is sent for an independent review to An Bord Pleanála, that decision is reversed?

In short, we must be realistic about the prospects for the NPF. There is growing academic evidence of the widening gap between the theory and practice of spatial planning, and Ireland is obviously a clear case in point. In fact, it is difficult to point to any instances where national spatial planning has actually worked. Simply, persisting with all of the borrowed buzzwords of the late 1990s (e.g. balanced development, gateways, hubs, networks etc) for continuity’s sake would be foolish in the extreme. So would be to try to ignore the contentious spatial politics at national level by shirking responsibility to the new ‘super regions’.

The fact of the matter is that Ireland is not a blank page onto which we can sketch abstract spatial policies. This has been amplified by the legacy of the Celtic Tiger which has accreted a complex economic, social and political geography which creates manifold path dependencies which cannot now be unpicked. These geographies are adversarial to national planning and present as countervailing headwinds to any strategy aimed at focusing development and infrastructure into a limited number of growth centres. Our widely dispersed settlement patterns make both the politics and technicalities of such explicit choices impossible. In fact, it is hard to conceive of a more unfavourable environment for conducting national spatial planning. Concentrating resources in one location inevitably means withdrawing them from others. Spreading them too thinly automatically undermines a strategy aimed at spatial concentration. The recent HIQA report on the under-performance of regional ambulance services, and the subsequent political outcry, is instructive here.

So in the end the NPF, like its predecessor, will fudge it. Within the fog, all development regardless of location will be justifiable. This depoliticised consensus will of-course suit the wider elite political project of maintaining the primacy of Dublin and Ireland’s competitiveness at the global scale. The NPF and the illusion of balanced development implies a form of spatial Keynesianism whereby resources are redistributed territorially. However, imposing artificial constraints on the growth of Dublin will inevitably be presented as counter-productive. FDI will simply not move to peripheral regions, but overseas. Figures released by the DJEI show that almost half of all FDI jobs created in 2013 were in Dublin with Cork, Galway and Limerick accounting for the majority of the balance. Demographic analysis by the Western Development Commission also shows that population is projected to become more regionally concentrated, particularly in Dublin and the Mid-East regions.

We have previously marshaled great effort and expense to produce a NSS which ultimately proved pointless. Before we embark on another fool’s errand we should first be asking ourselves the simple question – unless we are willing to confront the spatial politics that such a strategy implies, is there any point? Our experience is clearly that a spatial strategy based on a bland depoliticised consensus is equal to no strategy at all.

Gavin Daly

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2 Responses to “Any Development, Any Place, Any Time – Where Next for the NSS?”

While I acknowledge that the track record of most former ministers inspires little confidence, the idea of handing such power over to a technocratic regulator outside of democratic oversight would be fraught with danger. It cannot be simply assumed that the regulator would be a benign or progressive force.

They may just be hoping for corruption on a level that brings some coherence to planning, rather than the ad-hoc, piecemeal corruption with which we currently contend.

I would disagree with the argument that the NSS failed “due to thousands of individual acts of resistance…which cumulatively undermined the whole foundations of the strategy”. I would suggest that the main reasons the NSS failed were profound weaknesses in the strategy itself, in the provisions for its implementation and in, not just a lack of support for the strategy within the top echelons of the political class and the state bureaucracy, but active hostility to the strategy in these quarters.
Thus, there was no championing of the NSS by the Minister for the Environment and Local Government, who was charged in the NSS document with responsibility for leading implementation. I am not aware that the interdepartmental and ministerial committees which were supposed to supervise and monitor implementation of the NSS ever functioned – there is certainly no record of this.
Nor did the NSS document make any provision for the type of governance arrangements required for effective implementation. In particular, the lack of institutional structures at regional level capable of mobilising regional actors and coordinating public sector functions was never addressed. Instead, the NSS looked to voluntary liaison between local authorities which themselves lacked both the powers and status required to perform these functions.
The crucial element of the NSS was the creation of specialised export bases, built on dynamic economic sectors, in and around the selected gateway centres. However, the document failed utterly to address how these export bases might be created, an issue that was simply passed off as the responsibility of the enterprise promotion agencies. Instead, the NSS document dwelled on issues such as housing, transport and social facilities which would only become relevant if the document’s economic objectives were to be achieved (which, of course, didn’t happen). This, in large part, derived from the fact that preparation of the NSS was carried out by personnel within the Department of the Environment and Local Government, which has little or no expertise in the area of economic planning.
I would also disagree with the apparent equation here of the NSS with spatial Keynesianism i.e. “artificial constraints” on the growth of Dublin and territorial redistribution of resources. The NSS specifically rules out placing any restrictions on the growth of Dublin, and looked instead to the aforementioned creation of dynamic regional economies capable of successfully competing in the international economy and thereby generating sufficient population growth to at least slow down the trend towards concentration in the Dublin region. The current housing and commercial property boom in the latter region is testament to the utter failure of the NSS in this respect.